MAS Consultation on Measures to Enhance Investor Recourse Avenues in Market Misconduct Cases

Letter to the Monetary Authority of Singapore (MAS), 11 December 2025.

We refer to the invitation from the Monetary Authority of Singapore (MAS) to comment on the consultation paper on proposed enhancements to strengthen the investor recourse regime. We appreciate the opportunity to provide feedback as MAS considers how to enhance shareholder protections in market misconduct cases.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank and is responsible for investing the Norwegian Government Pension Fund Global. NBIM is a globally diversified investment manager with SGD 2.46 trillion invested in 62 countries as of 30 June 2025, of which SGD 7.91 billion was invested in the shares of 65 Singapore Exchange-listed companies.

As an investor with around 70 percent of our holdings in listed equity, we depend on thriving public markets that foster long-term economic value creation. Robust minority shareholder protections and investor recovery frameworks are fundamental to well-functioning and resilient public markets; they facilitate fair treatment of all shareholders, transparent and timely disclosures, and deter market misconduct and fraud.

We therefore welcome these measures to enhance investor recourse in market misconduct cases. Whilst the measures are intended for retail investors, the effective investor protection and recovery framework they establish ultimately strengthens market integrity, which benefits long-term institutional investors like us. We particularly welcome the openness to participation by institutional investors in investor groups with designated representatives.

Please find in the annex our responses to the consultation questions. We thank you for considering our perspective and remain at your disposal should you wish to discuss these matters further.

Yours sincerely

Carine Smith Ihenacho
Chief Governance and Compliance Officer                                                                          

Jeanne Stampe
Lead Policy Advisor                   

Download the letter and appendix (pdf)